UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 Illi. - 6:10 lli. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-15521 Electronically signed by Pamela Sullivan (501.333-772-1552) 41151584-6022-4050-b036-0423518c2lb5 EFTA00723105 15 14 17 18 19 20 21 22 23 24 25 APPEARANCES! 6 On behalf of the Plaintiff, /env Doe: 3 BRAD J. ED WARDS. ESQ1.7IRE ROTHSTEIN ROSIDIPELDT ADLER Las Oles City Cant, Stitt 1650 401 East Las Clef Soignee:I Fan Lsoladde, Florida 33301 11 12 13 Onel,alfoftherktadaa, Jeffrey Epstein: ROBERT D. CRITTON.M. ESQUIRE BURMAN, CIUTTON.LAD1TER & COLEMAN, LLP 303 Ewan Boulevard Suite 400 North Pahn Beech, Florida 33401 On Wu for the Defendant. Jeffrey Eptlein- JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY. GOIDEERGER & WEISS'S t1 250 Auendon Mesa Sou& Suite 1400 Were Palm Bach, Florida 334014012 On behalf of Plantar in Related Cass No. 0540469 ISIDRO M. GARCIA, (RE GARCIA LAW FIRM 224 Dame Steel, Suite West Palm Beach, Pkwitla 33401 561.532.7732 [email protected] On behalf of lone Dons 1 throne, ADAM D. HOROWTTZ, ESQU MERMELSTERS & HOROW117M7.. 18205 Mayne Boatyard Suite 2218 Ml&M Floral 33140 Page 131 1 2 3 4 5 6 7 Page 133 - - - INDEX - - DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. curroN 5 EXHIBITS MARKED 9 10 11 DESCRIPTION 12 Deft:odic:Ws No. 5 13 (Order) 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 163 Page 132 1 On behalf of the Plaintiff= 2 JACK P. HILL, ESQUIRE SEARCY DENNEY SCAROLA BARNHART & SHIPLEYS. 3 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 4 5 On behalf of the B.B.: 6 ADAM J. LANGNO, ESQUIRE LEOPOID RUM 7 2925 PGA Boulevard, Suite 200 Palm Berndt Girders, Florida 33410 a 9 11. 12 13 14 15 16 17 18 19 20 21 22 -23 24 25 ALSO PRESENT: Jeffrey Epstein, via video conference Stan Sanders, Videograpber 1 2 3 4 Page 134 PROCEEDINGS (Continued from Volume lof the same day.) VIDEOGRAPHER: Back on the record at 11:52. 5 BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 7 think, Malt 4 what 1 know to be Exhibit 4, which 8 is the declaration of Ms. Villafana. Do you see that? 9 A. Yes. 10 Q. And I will represent to you, and I think you 11 told me you don't know who she is; correct? 12 A. Yes 13 Q. And on Page 2, she says is, "I" — in her 14 declaration says — the first sentence says: "I am the 15 Assistant US — United States Attorney, assigned to the 16 investigation of Jeffrey Epstein," and then — "and the 17 case was investigated by the Fetal Bureau of 18 Investigation, FBI," et cetera, et cetera. 19 Do you see that up at the top? 20 A. Yes. 21. Q. Okay. That's who she says she is. And then 22 she's — on Page 7 of her declaration she says: "I 23 declare, under penalty of perjury, pursuant to 28 USC, 24 Section 1746, that the following is true and correct, to 2 5 the best of my knowledge and belief." And then she (561) 832-7500 2 (Pages 131 t o _124 ) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333772.1662) Electronically signed by Pamela Sullivan (501-333472 11652) 4415168d4k22-4c60-130364423618e2fb6 EFTA00723106 Page 135 1 signs this on 9th day of July 2008, and then it purports 2 Lobe what is her signature above her printed name. 3 Do you see that? 4 A. Yes. 5 Q. All right. If I go to paragraph three, down 6 at the bottom it says here -- there's a reference to 7 Jane Doe, Page 3 — sorry — Page 2, paragraph 8 three. Are you with me? 9 A. Yes. 10 Q. Go up — not — not the footnotes. You brow 11 what a footnote is; don't you? 12 A. Yes. 13 Q. All right Go up from the footnotes, then 14 one, two, three lines up it says: "Jane Doe was 15 identified." 16 Do you see that? 17 A. Yes. 18 Q. You are that Jane Doe; correct, Jane Doe? 19 A. Those are my initials. 20 Q. And -- and if you read in fact, I should 21 probably have you just — why don't you read to yourself 22 paragraph three, because there's a reference to 23 Mr. Edwards and three of his clients, C.W. and 24 Jane Doe. Do you see that? 25 A. Yes, I do. Page 137 1 Do you see that? 2 A. Yes. 3 Q. And then it says: "The FBI's Victim Witness 4 specialist sent a letter to Jane Doe," you, "on May 30, 5 2008." 6 Do you see that? 7 A. Yes, I do. 8 Q. Okay. You indicated that you were -- when I 9 asked you earlier today — excuse me — when you had 10 given your statements and you said, emphatically, you 11 were three and a half months pregnant; correct? 12 A. Yes. 13 Q. All right You wouldn't dispute 14 Ms. Villafana's and the FBI's agents' statement that 15 they interviewed you on May 28th of '08; correct? 16 A. No. 17 Q. And I think you — well, I don't think. Let 18 me start again. 19 You've told us you've testified that you 20 only talked with the FBI on one occasion, and that one 21 occasion had to have been May 28th of '08; correct? 22 A. Yes. 23 Q. Okay. And that was the first time, at least, 24 that you had told any governmental authority, state, 25 Federal, local, that you had been to Mr. Er:stain's home; Page 136 Q. Okay. would be -- 2 A. Yes. 3 Q. — you would assume. C.W. would be E.W., and 4 you would have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss - 7 Mr. Edwards represents, other than you, a and E.W.? 8 A. No. 9 Q. All right. Then it goes down — again, 1 10 take you back where it says: "Jane Doe was identified 11. via the FBI's investigation in 2007, but she initially 12 refused to speak to investigators." 13 Do you see that? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: Yes, h do. 16 BY MR. CRITTON: 17 Q. And Mat's true; you did refine to speak with 18 them? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: Yes. Yes, l did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th. 25 2008." Page 138 1. correct? 2 A. Yes. 3 Q. And if you go to Exhibit 5 — 4 MR. CRITTON: And, Mr. Edwards, if you could 5 help your client. 6 MR- EDWARDS: I haven't seat an Exhibit 5 7 yet, I don't think. S MR. CRITTON: It's — sorry. Exhibit 5 9 to Exhibit 4. My fault. 10 MR. EDWARDS: Okay. Just to show her where 11 it is. It's -- if you look up at the upper, 12 right-hand corner, there's a May 30th letter. 13 MR. CRITTON: May 30,2008, letter. les: 14 "Dear Jane Doe," and it's been redacted in part. 15 MR. EDWARDS: Let's see if I can get there, 16 and then ru get her there. 17 BY MR. CRITTON: 18 Q. If you look — you're now looking at 19 Exhibit 5 to our Exhibit 4; correct, to Ms. Villafana's 20 declaration? 21 A. Okay. 22 Q. And you see it's a letter from the US 23 Department ofJustice. It's dated May 30th, 2008, and 24 it says: "Dear Jane Doe," because your name has been 25 redacted; correct? (561) 832-7500 3 (Pages 135 to 138) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela moan (5014334724 (552) Electronically signed by Pamela Sullivan (601-333-7724552) 4f151584-6c22-4c50-b036o423618c2fbS EFTA00723107 Page 139 1 A. Uh-huh. Yes. 2 Q. And is this the Victim's Assistance Program, 3 a letter that you said you received sometime after you 4 met with the FBI? 5 A. Yes. 6 Q. Okay. And I think you said — your your 7 best recollection was within a watt, which is consistent 8 with this letter, which also then reconfirms that the 9 FBI had to have met with you, as reflected in the 10 declaration on May 28th, 2008, for the very first time; 11 correct? 12 A. Yes. 13 Q. All right. At the time that you received 14 this letter, 'think you also told us that you had not 15 been represented, or you Mr. Edwards was not 16 representing you at that time; correct? 17 MR. EDWARDS: Object to the form. 18 THE WITNESS: Yes, it was shortly after. 19 BY MR. CRITTON: 20 Q. All right. If you then go down to Exhibit 7, 21 and it's easier to read. 22 MR. EDWARDS: Flip a few pages. 23 THE WITNESS: Here? 24 MR EDWARDS: Keep going (inaudible). 25 THE WITNESS: Okay. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 141 does that refresh your recollection that the FBI told you that you could file some sort of civil suit against Mr. Epstein? MR. EDWARDS: Object to the form. THE WITNESS: Yeah, they — they may have mentioned something of it. BY MR. CRITTON: Q. Okay. So that — that refreshes your recollection that the FBI said, You know, you may want to go get your own lawyer and bring a money — a civil suit against Mr. Epstein; we're only criminal people? M. EDWARDS: Object to the form. BY MR. CRITTON: Q. Does that refresh your recollection? A. Which document refreshes her recollection? Any of this? MR. CRITTON: No, I just quoted back to her what she said to me. MR. EDWARDS: Okay. Well, if you know the answer to what he's talking about, then answer it. THE WITNESS: They didn't — I know — I mean, I don't remember what exactly they said to me, but they did mention that I should get a lawyer. Page 140 1 BY MIL CRITTON: 2 Q. This is a letter also from the US Department 3 of Justice. It's from Ms. Villafana. It's directed to 4 Mr. Edwards. It's dated July 9th, 2008. 5 A. Uh-huh. 6 Q. And it says, Re: Jeffrey Epstein/S, and then 7 there's a redaction, ft/Notification of Identified 8 Victim. 9 Do you see that? 10 A. Yes, I do. 11 Q. Okay. Have you ever seen this letter before? 12 A. I don't remember seeing this. 13 Q. Now, having seen the affidavit, Exhibit 4, 14 that is the declaration of Ms. V illafana that reflects 15 that you met with the FBI on May 28th, and consistent 16 with your earlier testimony, that you got the victim's 17 assistance letter shortly thereafter, which we now know, 18 from looking at one of the exhibits to the declaration, 19 was May 30th of '08. 20 Does that in any way refresh your 21 recollection how you got -- or from whom or how you got 22 the card to go find Mr. Edwards? 23 A. Well, no. 24 Q. Okay. And now, having seen the declaration 25 in exhibits -- and the exhibits that we've identified. Page 142 I. BY MR. CRITTON: 2 Q. All right. And that you might be able to get 3 money? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't — leant remember 6 them saying anything to me about money. 7 BY MR. CRITTON: 8 Q. Then why would you need a lawyer under these 9 circumstances for any reason? You weren't — or did. 10 they indicate to you that you were a target of any 13. investigation? 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: Basically, they just told me 14 that what happened to me was wrong, and that I 15 should do something about it. 16 BY MR. CRITTON: 17 Q. Okay. And you understood that doing 18 something about it was filing a lawsuit against 19 Mr. Epstein and ask for money? 20 MR. EDWARDS: Object to the form. 21 BY MR. CRITTON: 22 Q. Is that a fair statement? 23 A. Well, I wanted to have him prosecuted for 24 what he did, but I obviously can't do that. 25 Q. Because — because you know from your own (561) 832-7500 4 (Pages 139 to 142) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (601.333.772-'1662) 4115158d-6c22-4c50-b036-e423618c2fb5 EFTA00723108 Page 143 1 criminal experiences that it's either the State of 2 Florida or the United States Government that prosecutes 3 people, not individuals; true? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't understand. 6 BY MR. CRITTON: 7 Q. Well, you know that you can't prosecute -- a 8 citizen doesn't have the right to prosecute. It's — 9 ifs an arm of the Government, and you know from your 10 own experience. That is, when you got in trouble with 11 the law, you know it was the State of Florida versus 12 you; comet? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: That's not something that I 15 specifically 'mew from my own experience, no. 16 BY MR. CRITTON: 17 Q. Okay. Well, well get to that a little 18 later. Let — let me go back to the discussions that 19 you had with the FBI. I think you told me — well, I 20 know what I wanted to ask you. If you go back to 21 Exhibit 4, Page 2 — 22 A. (Witness complies.) 23 Q. — same paragraph, paragraph three. It says: 24 Attached hereto are copies of letters provided to 25 Mister — or to Bradley Edwards, three el lects,.., Page 145 1 Third sentence says: "All three of those 2 clients were victims of Jeffrey Epstein's while they 3 were minors, beginning when they were 15 years old. 4 Do you see that? 5 A. Yes, I do. 6 Q. Okay. So Ms. Villafana, based upon her 7 knowledge and the interview or the conversation that she 8 had with the FBI and the information they had, have you, 9 NB. and E.W. all being at least 15 when you first saw 10 Mr. Epstein do you see that, at least what's 11 represented in her sworn statement — 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: Yes, I can see what it says. 14 BY MR. CRITTON: 15 Q. All right. Did the FBI at any time — well, 16 let me — let me ask this question: If the FBI -- if 17 you told the FBI that you were 15 when you first saw 18 Mr. Epstein, based upon this declaration, does that now 19 refresh your recollection that you never went to 20 Mr. Epstein's home for the first time until after you 21 turned 15, which would have been sometime after June 22 17th of 20037 23 MR, EDWARDS: Object to the form. 24 THE WITNESS: I remember specifically telling 25 than and Jeffrey that INNIS 14 when I first met Page 144 1 C.W. and Jane Doe. And then there's a 1 for the 2 footnote. 3 Do you see that? 4 A. Yes. 5 Q. All right. And, again, recognizing that 6 Ms. Villafana is a United States Attorney, and that 7 she's signing this declaration of oath under oath, based 8 on her conversations that she had with the FBI -- at 9 least that's what it purports to say — but go down to 10 Footnote 1. It says: "Attorney Edwards filed this 11 motion on behalf of lane Doe, without identifying which 12 of his clients is the purported victim?' 13 Did I read that correctly? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: I don't know. 16 BY MR. CRITTON: 17 Q. I want you to follow along. Did I just -- 18 let me read it again. 19 A. Oh I read it ahead of you. 20 Q ■ sorry? You're ahead of me? 21 A. Yeah. 22 Q. Okay. Well, then, we'll just — let me go to 23 the second sentence. It says: Accordinglywill 24 take — I will address facts related to C.W.,M. and 25 Jane Doe. Page 146 1 Jeffrey, and I told him that 1 was 15. 2 BY MR. CRITTON: 3 Q. Okay. Well, but you would agree with me that 4 at least Miss — the FBI and the US Attorney's Office 5 believed you were 15, based on something that you told 6 them; cone& 7 MR. EDWARDS: Object to the form. 8 THE WITNESS: It looks like that's what they 9 believed. But they obviously misinterpreted what! 10 told than, because I know what I told them. 11 BY MR. CRITTON: 12 Q. Would you agree with me that your 13 recollection back in 2000 -- May of 2008 was probably 14 better than it is today 15 MR. EDWARDS: Object to the form. 16 BY MR. CRTITON: 17 Q. -- in September of 2009? 18 A. What do you mean? 19 Q. Well, would you agree that with another -- 20 let's see - with another 16 months having passed since 21 May of 2008, that your recollection as to the events 22 involving Mr. Epstein were better back in 2008 than they 23 are now? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: No. 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) (561) 832-7506 4f15158d-6c22.4c50-b036-e423618c21b5 EFTA00723109 Page 147 1 BY MR. CRTITON: 2 Q. Okay. You think your recollection is better 3 now? 4 A. No, I think it's pretty much the same. 5 Q. All right. You told me the FBI -- well, let 6 me strike that. 7 You said you told the FBI how you came to be 8 at Mr. Epstein's the first time; correct? 9 A. Yes. 10 Q. diaLin response to their question, you told 11 them than. took you; correct? 12 A. Yes. Yes. 13 Q. How many times did — did you go or dical. 14 take you to Jeffrey Epstein's home? 15 A. One. 16 Q. Just the first time? 17 A. Yes. 18 Q. And what dill. tell you about -- well, let 19 me strike that. 20 You were friends within.? 21 A. Yes. 22 Q. And you say it was, at least your 23 recollection today, is it was sometime in February, plus 24 or minus a month, of '03? 25 A. Yes. Page 149 1 Initially acquaintances, but eventually friends? 2 A. Yes. 3 Q. Lets sec. Duncan Middle School, where you 4 would have been there sixth, seventh and eighth? 5 A. No. I went there for sixth grade, and I 6 moved in seventh grade. 7 Q. Dial. stay there? 8 A. 1 daft know. 9 Q. Where did you go for seventh grade? 10 A. Okeeheelee Middle School. 11 Q. Is that because you moved locations where you 12 were living? 13 A. Yes. 14 Q. Okay. And in sixth grade you would have 15 been - lets see -- sixth grade you would have been how 16 old? 17 A. Eleven. 18 Q. Who were you living with — who were you 19 living with when you went to Duncan Middle? 20 A. My grandmother. 21 Q. Ms. Brewer? 22 A. Yes. 23 Q. (Way. Who were you living with when you went 24 to Okeeheelee? 25 A. I was in between my grandmother and my Page 148 1 Q. All right. When you went the first time - 2 or before ou went the first time, how long had you 3 known.? 4 A. About three years. 5 Q. And did you meet — how did you meetM.? 6 A. I met her in the sixth grade at school. 7 Q. Was she in your class? 8 A. No. 9 Q. Is she older or younger, same age? 10 A. I think she's a little bit younger, but she's 11 about the same age. 12 Q. You mean within a couple of months of one 13 another? 14 A. Yes. 15 Q. How about E.W., by the sixth grade did you 16 already know E.W.? 17 A. No. 18 Q. Sot was the first person you knew? 19 A. Yes. 20 Q. What school was that? 21 A. Watson B. Duncan Middle School. 22 Q. You were in the same sixth grade, just 23 different classes? 24 A. Yes. 25 Q. Did you know -- and you became friends? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 150 mother. Q. Is this during the time that is between the sixth and the seventh grade, is this the time that your — that the incident occurred whore your father had been charged with, in essence, murdering Joey? MR. EDWARDS: Object to the form. THE WITNESS: It was summer before seventh grade. BY MR. CRITION: Q. Is that the reason that you were no longer with your grandmother at that point in time, and why you went to Okeeheelee? A. I was with my grandmother. My grandmother moved because my mother wanted me to go to that school because she wanted the school to believe that I was living with her. Q. She wanted you to go to Okeeheelee? A. Yes. She wanted -- I dont know who really, but she wanted somebody to believe that I was living with her, and not with my grandmother. Q. So mom said, come, you're staying with me, and — and, ultimately, you went to Okeeheelee? A. Yes. Q. Did you stay in touch with II.? A. No. (561) 832-7500 6 (Pages 147 to 150) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-772-1552) Electronically signed by Pamela Sullivan (501-333.772.1652) 415158(1-6c22-4c50-b0364423618atb5 EFTA00723110 Page 151 1 Q. When you were in sixth grade, did you and 2 used to play together? 3 A. No. 4 Q. Did you -- you just knew each other from 5 school? 6 A. Yes. 7 Q. Did you ever meet..'s mom? 8 A. No. 9 Q. Have you ever met..'s mom? 10 A. No. 11 Q. Has.. ever talked to you about her morn? 12 A. No. 13 Q. Has anyone ever told you that..'s mom is a 14 prostitute? 15 A. No. 16 MR. EDWARDS: Object to the form. 17 BY MR. CRITTON: 18 Q. Have you heard that before today, that..'s 19 mother was a prostitute? 20 A. No. 21 Q. Did you seell. during your seventh grade at 22 all? 23 A. No. 24 Q. How about eighth grade? 25 A. We were living close to each other, so I met Page 153 1 A. No. 2 Q. -- legal or illegal? 3 A. No. 4 Q. Prescription drugs that — although they 5 weren't your prescription? 6 A. No. 7 Q. Were you aware that.. was doing drugs -- 8 A. No. 9 Q. — or alcohol back at that poim in time in 10 sixth, seventh and eighth -- sixth and seventh grade? 11 A. No. 12 Q. How about eighth grade, were you — had you 13 started drinking by the time you had hit eighth grade? 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITPON: 16 Q. By drinking, I mean alcohol. 17 A. I — I had probably had a drink at some 18 point. 19 Q. And had you started doing drugs by the time 20 you were in the eighth grade, illegal drugs? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: Yes. 23 BY MR. CRITTON: 24 Q. All right. And what had you started? 25 Smoking pot? Page 152 1 her again, yes. 2 Q. In eighth grade, were you still at 3 Okeeheelee? 4 A. Yes. 5 Q. But you were living closer now to.., so 6 you started hanging out together or were friendly, 7 became friends again? 8 A. We hung out once in a while, not a whole lot. 9 Q. And I think you said you never have been to 10 M.'s house? 11 A. No, I had never — 12 Q. Back at that point in time. 13 A. No. 14 Q. Okay. Had she ever been — had you ever 15 brought her over to your house or your grandmother's 16 house or wherever you were living at the time? 17 A. Yes. 18 Q. And this would have been in what, in eighth 19 grade now we're talking about? 20 A. Yes. 21 Q. Okay. When you were in sixth grade and 22 around., did you and. ever drink alcohol 23 together? 24 A N 25 Q. Did you ever do any kind of drugs together — racc2 3 4 5 6 7 8 9 10 11 12 13 14 15. 16 17 18 19 20 21 22 23 24 25 Page 154 A. Yes. Q. All right. How about the Ecstasy, the one Ecstasy that you say you took, was that back in the eighth grade? MR. EDWARDS: Object to the form. THE WITNESS: I was either 13 or 14. BY MR. CAPTION: Q. So at least before you met Mr. Epstein, you had at least done — you were drinking alcohol, you were using pot, and you had had Ecstasy; true? MR. EDWARDS: Object to the fonn. THE WITNESS: Yes. BY MR. CR1TTON: Q. And had you also had Xanax by age 12,13, 14? A. No. Q. Did you ever smoke pot with..? And. talking eighth grade. A Probably. Q. And how about Ecstasy, were you or. — well, let me strike that. Had you ever taken Ecstasy when.. was around? A. No. Q. Okay. Who were you with when you had the Ecstasy? (561) 832-7500 PROSE COURT REPORTING AGENCY, 7 (Pages 151 to 154) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 4,15158d-6c22-4c50-b036-e423618c211,5 EFTA00723111 Page 155 1 A. I was with an old friend. 2 Q. Who? 3 A. Melissa. 4 Q. What's Melissa's last name? 5 A. Kapusta. 6 Q. • sorry? 7 A. K-a-p-u-s-t-a. 8 Q. Is she a friend of yours? 9 A. I haven't seen her or spoken to her in a few 10 years. 11 Q. Did she used to live out -- or in the area 12 that you did? 13 A. Yes. 14 Q. Is she older, younger, or same age? 15 A. Well, she went to the same school. We were 16 the same age. She was — she's a little bit younger, a 17 few months. 18 Q. Okay. And when you would smoke pot, who did 19 you get that Ran? 20 MR. EDWARDS: Object to the form. 21 THE WITNESS: I don't know. 22 BY MR. CRITION: 23 Q. Okay. Did you ever get it from your 24 grandmother? 25 A. Na Page 157 1 A. She was friends with my friend. 2 Q. She being who? E.W.? 3 A. E.W. was friends with my friend, Melissa, and 4 that's how I met her. 5 Q. So you met E.W. through Melissa? 6 A. Yes. 7 Q. What age? 8 A. Thirteen or 14, maybe. S not positive. 9 Q. And did you and E.W. hit it off right away, 10 once you met through Melissa? 11 A. No, we did not. 12 Q. Did you ever smoke pot with E.W. back at that 13 time? Because she was using drugs, too; wasn't she? 14 MR. EDWARD$: Object to the form. 15 THE WITNESS: I don't know what she was 16 doing. 17 BY MR. CRITION: 18 Q. Okay. Are you saying she wasn't using drugs, 19 or you just don't know, one way or the other? 20 A. I just don't know. 21 Q. But you've used illegal dings with E.W.; 22 haven't you — 23 MR. EDWARDS: Object to the form. 24 BY MR. CRITTON: 25 Q. - from the time you met her? Page 156 1 Q. Okay. Did you ever smoke pot in your 2 grandmother's house? 3 A. Probably. 4 Q. Okay. Was she aware that you were smoking 5 pot? 6 A. No. 7 Q. after -- during eighth grade continued 8 to be friends? 9 A. Yes. 10 Q. Okay. When you say you went to Epstein's 11 house for the first time, what grade were you in? 12 A. I was in eighth grade for the second time. 13 Q. You repeated eighth grade? 14 A. Yes. 15 Q. So you would have still been at — at that 16 time at Okeeheelee? 17 A. In the middle of that year 1 believe I left 18 that school and went to an all girls school. 19 Q. Was that Pace? 20 A. Yes. 21 But you were still — you would still see 22 M. from time to time? 23 k Yes. 24 Q. Okay. Was was E.W. around this time, as 25 well? Were you friends now with E.W.? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 158 A. Yes. Q. Now, when you first met E.W., where was she living? A. She was living with her mom in — Q. Do you know what her morn's name is? A. Eva. Q. Did you ever go over to E.W.'s house, back at that time period — A. I - Q. - seventh, eighth, ninth grade? A. I went outside her house once. I — I had never been inside of her house. Q. But you met her mom? A No. Q. You never met her mom? A. I have met her mom, but at that point, no. Q Okay. Did you meet her mom after this lawsuit has been filed? A. No. Q Did you meet her at what point in time? A. I met her when I worked at IHOP. Q. Did she come in as a -- was she a waitress there, or did she — A. She worked there. Q. Did she help you get your job? (561) 832-7500 • ..4.••••••.••....laaa•• ••••••••....... 114• ••./.....• 8 (Pages 155 to 158) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4.16168tHic22-4c6043636-6423618c2k6 EFTA00723112 Page 159 1 A. Yes. 2 Q. And was that when you were living with E.W.? 3 A. Yes. 4 Q. Okay. That was when you were living with 5 E.W. at the apartment with Jessie? 6 A. Yes. 7 Q. And when — was there anybody else living 8 there at that apartment with you, Jessie and E.W. during 9 that few months that you were there in 2006? 10 A. No. 11 Q. And that's when you met mom — mum — E.W.'s 12 mother? sorry. 13 MR. EDWARDS: Foam 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. And did E.W. say, you need to get a job, you 17 know, why not -- maybe my mom can help you get a job at 18 IHOP? 19 A. No. I expressed to her that I wanted a job. 20 Q. Had you had a job before that point in time? 21 A. Not really a real job. I had — I had a job, 22 but I — I like went there fora week, and stopped. 23 Q. And that was where? 24 A. I worked foramen named Stan Crooks. 25 Q. Who Is Stan Crooks? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 161 and you were hanging out with..? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. You were friends — were friends with..? MR. EDWARDS: Object to the Porn. THE WITNESS: Yes. BY MR. CRITTON: Q. And at that time that M. first approached you, were you aware that E.W. — whether or not E.W. had been to Mr. Epstein's home? A. I didn't know fora fact, no. Q ESOrrY? A. II did not know fora fact. Q. And what did — what did III. tell you? A. About going to Jefft E ins house. Q. What did — what did . raise with you? That is how did the — before . ever told you or asked you whether.. be interestecS:oing to Mr. Epstein's home, did she -- that is M. — were you aware that she had been to Mr. Epstein's home? That is had she talked about it amongst you all? MR. EDWARDS: Object to the form. THE WITNESS: I had heard about it, not from Page 160 1 A. He is an auctioneer. He is my uncle's 2 friend. 3 Q. 4 home? A. No. 6 Q. Another uncle? 7 A. Yes. 8 Q. Another brother of Mr. Dial? 9 A. Yes. 10 Q. What's his name? 11 A. Oakley. 12 Q. Is his first name? 13 A. Yes. 14 Q. What's his last name? 15 A. Brown. 16 Q. They — looks like theres a — was it a 17 Jeff Brown? 18 A. Yes. 19 Q. A Jeff Brown and Oakley Brown, but they're — 20 are they like stepbrothers with your dad? 21 A. My dad was a first born. He has a different 22 father. 23 Q. All right. So I think you told me you would 24 have been at Mr. Epstein's house -- you would have been 25 in the eighth grade for the first time, eighth grade, The uncle who drove you to Mr. Epstein's Page 162 1 BY MR. CRITTON: 2 Q. What had you heard and from whom? 3 A. I don't remember who exactly it was. It may 4 have been..'s boyfriend at the time. 5 Q. Which boyfriend would that have been? 6 A. I don't know. I think probably her baby's 7 'Other. 8 Q. Justin Sprague? 9 A. Yes. 10 Q. Did you know Cory Sprague? 11 A. Yes. 12 Q. Okay. Did you ever have sexual relationship 13 with Justin Sprague? 14 A. No. 15 Q. Did you ever have one with Coxy Swam? 16 MR. EDWARDS: Object to the fonm.•• 17 instructing the witness not to answer, invoking her 18 privacy rights, privacy rights of third parties. 19 MR. CRITTON: Well, let me just do something 20 so we can get this on the record. 21 Is — let me have marked as Exhibit -- where 22 are we — 5. 23 (Discussion held off the record.) 24 MR. CRITION: Four was the declaration of 25 Marie Villafana. (561) 832-7500 PROSE COURT REPORTING AGENCY, 9 (Pages 159 to 162) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1662) Electronically signed by Pamela Sullivan (501.333.172.1662) 4115158d-6c22-4c50-b036-e423618c21b5 EFTA00723113 Page 163 1 This is going to be marked as Exhibit 5. 2 (Discussion held off the record.) 3 (Defendants Exhibit No. 5 was marked for 4 identification.) 5 BY MR. CFUTTON: 6 Q. Exhibit 5 is the order that Judge Johnson 7 entered on September 4,2009, in the consolidated case 8 that dealt specifically with Mr. Epstein's emergency 9 motion for independent medical exam, and it was directed 10 to Mr. Ifill's client, 11 Within — within that order, on Page 2 she 12 says — or dealt with questions that could be asked, the 13 scope of the exam. But Judge Johnson — 14 MR. CHINON: And I just want to put this on 15 the record, and then we can move on, if your 16 instruction is the same, Brad. 17 But she talks about it in the first paragraph 18 on the second page, first full paragraph. She, 19 Judge Johnson, who's dealing with a discovery 20 issue, says, the remaining issues involve 21 Plaintiffs request for an order limiting the scope 22 of the proposed examination by disallowing repeated 23 questioning regarding, quote, highly sensitive 24 areas of inquiry, including Plaintiffs medical 25 history, psychiatric history, sexual history, 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 1 2 3 4 5 7 9 0 2 3 4 5 6 7 6 0 1 2 3 4 5 Page 165 support her novel position that the Plaintiff who puts her mental, emotional and psychiatric state at issue can place a limitation on the number of times defense counsel, or agents retained by him, can inquire into areas relevant to these 'Min where the subject matter involved is highly personal, embarrassing, sensitive or otherwise humiliating. Plaintiff is seeking millions of dollars in personal injury damages for, among other things, physical injury, pain and suffering, emotional distress, psychological, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity and invasion of her privacy. And she on to describe at least specifically to And then the last two sections I want to just put on the record is on the first — first MI paragraph on Page 4. It says: Under these circumstances, where Plaintiff — MR. EDWARDS: Circumstances of-., that's what we're talking about; right? MR. CIUTTON: Right. Under these circumstances — MR. EDWARDS: Yes. MR. CRITTON: — where Plaintiff is seeking Page 164 1 social history, sexual abuse history, substance 2 abuse history, et cetera, and imposing certain time 3 restraints on the examination itself And the Court goes on to deny — the 5 Plaintiffs request to limit the scope of the 6 examination is denied. 7 And if you go over on Page 3, Judge Johnson 8 says: Presumably, Plaintiff—and there was a -- 9 there was a questionnaire that was being referenced 10 then — she says: Presumably, Plaintiff, who in 11 this instance to this older was-., but it 12 applies to every Federal court Plaintiff, will be 13 asked these questions two or more times, first by 14 defense counsel at And/tone's deposition scheduled 15 to take place shortly, and again by Dr. Hall at the 16 upcoming examination. 17 And then she goes on to say that Plaintiffs 18 objection is that, by having to answer these same 19 questions about the same subject matter three 20 separate times would only serve to embarrass, 21 humiliate, intimidate and further victimize the 22 Plaintiff. 23 She - she - Judge Johnson goes on to say at 24 the next full paragraph: Plaintiffs site no case 25 law, and independent research has uncovered none to 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 Page 166 1 to recover medical expenses associated with these 2 complex medical issues, full knowledge of the 3 Plaintiffs past and present medical, 4 psychological, familial, social histories is 5 essential. And while neither a duplication nor 6 embarrassment is desired, under the circumstances 7 presented, where the number and the scope of 8 damages claimed are vast and the Plaintiffs past 9 history eventful, it may nonetheless be 0 unavoidable. 1 And then she goes: This is not to say that 2 the restrictions on the scope of the questions may 3 never be put into effect, and if the case 4 progresses, and Plaintiff can show that Defendant's 5 invasive questioning is being done in bad faith or 6 for purposes of harassment, the Court may 7 reconsider imposing limitations of the sort 8 requested herein. 9 At this point however, the Court agrees with Defendant that to restrict the number of times 1 defense counsel may ask the Plaintiff personal and 2 sensitive questions concerning some of the pivotal 3 issues in this case would work an injustice by 4 preventing Defendant from being able to defend 5 himself. (561) 832-7500 SALL.N.a..“*.erIbLenf 10 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4115158d-t3c22-4c50-b036-e423618c2145 EFTA00723114 Page 167 1 So I don't know ;whether you have seen this 2 order — 3 MR. EDWARDS: Yeah. Well,1— I haven't 4 seen it, but having read that, it certainly doesn't 5 change my position. Ifs clearly talking about a 6 different Plaintiff different set of 7 circumstances. And very seldom, if ever, does it 8 talk about issues regarding the names of sexual 9 partners, sexual positions or sexual activity. It 10 talks about other things that 1 have let you 11 conduct your examination on. So... 12 MR. HILL: And the other thing is, is I filed 13 the motion so, to be included in this record, the 14 scope of the relief that I was seeking, the motion 15 for protective order. The motion to limit the Chit 16 was regarding repeated questioning in the same 17 areas of inquiry. Nothing about that motion for 18 protective order sought to prevent discussion about 19 past sexual history at all. It was to the number 20 of times it could be disclosed and discussed. 21 So to suggest that that is somehow a ruling 22 that everything is open game is not entirely 23 consistent with the relief that I was seeking in 24 that motion. 25 MR. EDWARDS: So if you want to make this an 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 169 MR. EDWARDS: If it relates to sexual partners' names or sexual positions and things that are obviously intended only to humiliate, yes, that's going to be my objection. MR. CRITTON: Now, Pam, if I could get you to go back to the question I asked. So long, Adam. (Whereupon, Mr. Horowitz left the proceedings.) (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) MR. CRITTON: Let me be clear on the question. Let me see the question preceding. COURT REPORTER: This is the preceding question... (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) BY MR. CRITTON: Q. All right. Let me just ask the question so it is clear: Did you ever have a sexual relationship with Cory Sprague? MR. EDWARDS: And instructing the witness not to answer, based on her own privacy rights, as well as the privacy rights of third-party, innocent persons. Page 168 1 exhibit, you can. 2 MR. CRITTON: just saying -- 3 MR. EDWARDS: It certainly doesn't change my 4 position. 5 MR. CRITTON: All right. And just saying 6 this is — we're going to come — I will certainly 7 ask the Court for relief - 8 MR. EDWARDS: Sure. 9 MR. CRITTON: -- for sanctions and the costs 10 and fees related to that. 11 ljust wanted to give you the opportunity to 12 read the order and what she said about defense 13 counsel asking repeated questions about these areas 14 or the number of times that they'll be asked, not 15 only by defense counsel — 16 MR. EDWARDS: It sounds like- 17 MR. CRITTON: -- but as well by the doctor. 18 So I think ifs an appropriate area. You can 19 still stay with your same instructions. 20 MR. EDWARDS: Yeah, it sounds like you can 21 ask it as many tunes as you want 22 MR. CRITTON: And you'll continue to object. 23 MR. EDWARDS: Well, it depends on the 24 question. 25 MR. CRITTON: All right Page 170 1 BY MR. CRITTON: 2 Q. Were you aware that-. has — as of today, 3 are you aware that at some point in time she had a 4 sexual relationship with Cory Sprague? 5 A. No. 6 Q. Are you aware that. had a sexual 7 relationship, not only with Justin Sprague, but as well 8 Cory Sprague? 9 MIL CR1TTON: Did I soya? Did 1 say — 10 MR. EDWARDS: Well, you just asked the same 11 question twice. 12 BY MR. CRITTON: 13 Q. Right. Are aware that E.W. had a sexual 14 relationship, as did..., with both Justin Sprague and 15 Cory Sprague? 16 A. I knew that E.W. had dated Justin before 17 did. 18 Q. Okay. Were you aware that she had a — had 19 sexual activity, both with — or with Justin Sprague? 20 A. No. 21 Q. Did she tell you that? 22 A. Well, E-W.? Yes. 23 Q. She told you she had had sexual relationship 24 with Justin Sprague? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, 11 (Pages 167 to 170) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-Sc22-tic50-b036-e423618c2fb5 EFTA00723115 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 171 Q. Did she tell — did she, E.W., as viell tell you she had a sexual relationship or had sexual activity with Cory Sprague? A. No. Q. Did you ever tell E.W. whether you had sexual activity with Cory? A. No. Q. Did you ever tell whether you had a sexual relationship with Cory? A. No. Q. Now back to how you learned about Mr. Epstein. I think ou said that Justin Sprague, who was the father of IM's son? A. Yes. Q. And his name is 'a? A. as son? Q. Yes. A. No. Q. What's his name? Q. That' • als right. gm =sorry. COURT REPORTER: Spell? BY MR. CRITTON: Q. Spelled? A. C-a-i-d-e-n. Page 173 1 Q. So if al has testified under oath that 2 Justin didn't care and just said, bring home the bacon, 3 that would be a surprise to you? 4 MR EDWARDS: Object to the form. 5 THE WITNESS: I wouldn't really care whether 6 Justin wanted her to go or not. That's none of my 7 business. 8 BY MR. CRITTON: 9 Q. And that was not my question. So ilgoing10 to ask Pamela to read it back to you, and if you could 11 answer my question, please. 12 (Whereupon, the requested portion of the 13 record was read aloud by the Court Reporter.) 14 BY MR. CRITTON: 15 Q Latae rephrase it, then. 16 If has testi under oath that Justin 17 said, being aware that l= was getting money from this 18 old guy in P 3each, that his response — Justin's 19 response to SE was, I don't care, just bring home the 20 bacon, that — 21 A. Well, =sure 22 Q. Let me finish the question. 23 — that would be a surprise to you, based 24 upon at least what you —your impression is from 25 Justin; is that correct? Page 172 1 COURT REPORTER: And Sprague? 2 THE WITNESS: I don't know his last name — 3 MR. CRITTON: S-p-r-a-g-u-e, I believe. 4 That's how I've seen it answered in 5 interrogatories. 6 BY MR. CRITTON: 7 Q. What did you hear fmm Justin, or what did — 8 what was Justin saying about Mr. Epstein? 9 A. That a was seeing some old guy, who was 10 paying her money. 11 Q. And Justin, did he think that was a good idea 12 because she was getting money? 13 MR. EDWARDS: Object to the font 14 BY MR. CRITTON: 15 Q. What did he say? 16 A. I think Justin was probably upset about it. 17 Q. And what malcskyou believe that Justin may 18 have been upset about going — or seeing some old 19 guy, as you — as he described it to you, who was paying 20 her money? What did he say? 21 A. I don't remember exactly what he said. 22 sure that he wasn't happy about it, though. 23 Q. What — what makes you believe that? 24 A. Because they were living together, and they 25 were, I guess, in a relationship. Page 174 1 MR.13DWARDS: Object to the form. 2 THE WITNESS: I don't know. 3 BY MR. CRJTTON: 4 Q. All right. You might not be surprised one 5 way or the other; true? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Yeah, that's true. 8 BY MR. CRITTON: 9 Q. Was Justin working at that time? 10 A. I don't know. 11 Q. How old was Justin at the time thte 12 was — he was having a relationship with MI.? And 1 13 guess you both -- if I understood, she probably was in 14 the ninth grade, because you were doing the second year 15 of eighth grade; correct? 16 A. I don't know. 17 Q. Is Justin older, younger? 18 A. I don't know how old — 19 Q. Were they — 20 A. —he is. 21 Q. Were they living together? 22 A. Yes. 23 Q. Where were they living together? 24 A. I don't know. Ina trailer. 25 Q. And how long had they been living together? (561) 832-7500 12 (Pages 171 to 174) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 015188d40.22465044136442X418c:db5 EFTA00723116 Page 175 1 A. I don't know. 2 Had you ever gone over and stayed -- or gone 3 to MM. and Justin's trailer and stayed — stayed there, 4 partied with them? 5 A. No. 6 Q. Hung out? 7 A. I had gone there before, yes. 8 Q. Okay. When Justin was there? 9 A. Yes. 10 Q. How many months before that you — before 11 that you first went to Epstein's? Had they been living 12 together a number of months? 13 A. I don't know. 14 Q. Okay. How long before had you been to 15 their — before Justin said something to you about IS 16 going over to — that some old guy was paying her? Was 17 that at least a month or two? 18 A. I don't know. 19 Q. Okay. Did they continue to live together for 20 a number of months? 21 A I don't know how long they lived together. 22 Q. How many times did you ever go to their 23 trailer? 24 A. Two. 25 Q. And did E.W. ever go with you? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 177 THE WITNESS: I didn't look into it. BY MR. CRITPDN: Q. some? A. I didn't look into it Q. Well, why did Justin even mention it to you? MR. EDWARDS: Object to the form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Did he tell you how much money she was getting? A. No. Q. Did he tell you what she was doing with hirn — A. No. Q. — for the money? A. No. Okay. Did she — did he tell you who the guy Q. was? A. No. Did he tell you where the guy was — No. Q. or where he lived? A. No. Q. He just said, is getting money from some older guy? A Page 176 1 A. No. Q. When you went to their trailer on those two 3 occasions, would it be a correct statement that you had both alcohol and smoked pot? 5 A. No. 6 Q. Okay. On either occasion did you smoke pot 7 when you were with Justin and a 8 A. Probably on one. 9 _S. Okay. And did you ever have alcohol with 10 Ng and Justin, as well? 11 A. No. 12 Q. Okay. So Justin tells you.. was getting 13 money from some older guy. Did she — 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITTON: 16 Q. Is that correct? Before — beforeM. ever 17 referenced milting to you or said anything to you? 18 A. Yes. 19 Q. Okay. And when he said — when Justin told 20 you that, was anybody else present? 21 A. I don't know. 22 Q. What was your reaction-- well, let me ask 23 you this: What did Justin — did you say, well, what do 24 you mean she's getting money from an older guy? 25 MR. EDWARDS: Object to the form. Page 178 1 A. Yes. 2 Q. Okay. And what did you interpret that in 3 your own mind to mean? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't know. 6 BY MR. CRITTON: 7 Q. Okay. Did you — did you wonder why.. was 8 being paid money by some person just to go to his house? 9 MR. EDWARDS: Object to the form. 10 THE WTINESS: Sure I wondered, but I didn't 11 at 12 BY MR. CRITTON: 13 Q. Had — to your knowledge, hadll. ever 14 received money from men for doing things, whatever those 15 things might be? 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: I don't know. 18 BY MR. CRITTON: 19 Q. Okay. She may have; she may not. You just 20 don't know, at least at that point in time; right? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: I don't know. 23 BY MR. CRITTON: 24 Q. That's what saying. Listen to my 25 question. As of the time that Justin raised the issue 13 (Pages 175 to 178) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501433-772-1652) Electronically signed by Pamela Sullivan (501-333-T/2-1552) (561) 832-7506 4f15158d-6c22.4c50-b036-e423618c2fb5 EFTA00723117 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 179 with you, before you went to Mr. Epstein's the first time, that was getting some money from some old guy, do you -- do you have any knowledge whether she had ever received money from a young person or an old person for doing anything? A. No. Q. Was anybody else present when Justin said that to you? A. I don't know. Q. Well, when's the next time — how much — how much time passed before again the issue of getting money for — from some older nun — MR. EDWARDS: Object to the tbnn. BY MR. CRITTON: Q. -ante up again? A. I don't know if it did. Q. Okay. Did you tell the FRI that Justin Sprague had mentioned that was getting money from an older guy? A. No. Q. Okay. You're tell — just telling us that now? MR. EDWARDS: Object to the form. THIEWITNESS: Yes. Page 181 1 Q. Do you remember when that was? 2 A. No. 3 Q. Did they give you cards? 4 A. Yes. 5 Q. Do you still have those cards? 6 A. No. 7 Q. What did you do with those cards? 8 A. I don't know. 9 Q. Did you ever turn them over to Mr. Edwards? 10 A. I don't think so. 11 Q. Okay. You said there were two lawyers, but 12 whatever the card said was who they were? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. How much time did they spend with you? 17 A. I don't know. 18 Q. More than five minutes? 19 A. I don't know. 20 Q. More than an hour? 21 A. I don't know. 22 Q. Okay. So you can't you said two 23 individuals who — who were there on behalf of 24 Mr. Epstein met with you, talked with you. You don't 25 know — you can't tell me the date or even the year, Page 180 1 BY MR. CRITTON: 2 Q. By the way, have you ever given any 3 statements to anyone else? Anybody else ask you about 4 Epstein at any lime? 5 MR. EDWARDS: Objection. Don't answer. 6 Attorney-client privilege. 7 BY MR. CRITTON: 8 Q. Well, except -- and 1-- when I ask questions 9 Illce that — and Emd will still make his objections, 10 which will remind me — not interested whether 11 some — Mr. Edwards or someone from his office asked 12 you. You know, — confident that he inter